EFTA01108851

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Page 575 
A. Yes, I did. 
Q. And did you pay on the amount of income 
you actually earned? 
MR. EDWARDS: Object to the form. 
THE WITNESS: It's none of your damn 
business. 
BY MR. LUTHER: 
Q. Do you know that filing a false tax return 
is a crime? 
A. Yeah, and it wasn't false. Kiss my ass. 
Q. So your, your tax return is in '08 is 
correct; is that right? Is that what you are 
telling us? 
A. No. 
Q. Is it false? 
MR. EDWARDS: Just read. 
BY MR. LUTHER: 
Q. Now, you allege in your complaint that you 
have suffered, and I am going to list a series of 
things. 
A. Yeah. Can you tell I am suffering? 
Q. Well, ma'am —
A. Can you tell I am suffering? I hate Jeffrey 
Epstein, and I hope he bums in hell. 
On advice of counsel, I am invoking my 
Page 576 
Fifth Amendment rights under the United States 
Constitution. 
Q. To anything in particular or just malting 
that statement? 
A. To the question you asked me about my taxes. 
Q. That question has already been answered. 
A. Oh, okay. Next. 
Q. In your complaint you allege that you have 
suffered emotional distress, psychological trauma, 
mental anguish, humiliation, embarrassment, loss of 
esteem, loss of dignity, invasion of your privacy. 
A. Amen. Yes, I have. 
Q Have you —
A. All of the above. 
Q. Have you described for me thus far in this 
deposition all of those elements that you allege of 
damage that you allege you suffered or is there 
A. Yes, I have. And you already know the doctors 
in the last deposition. 
Q. And you said some guy who is no longer in 
business out on Okeechobee. Anybody else? 
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Page 5 
Q. Then you went to him 
tse you said you 
had your son in Publix, I think, and you had a panic 
attack? 
A. 
alWhen 
was the last time 
I 
yo mes
is 
• 
A. I don't know. I couldn't tell you. Why don't 
you look at the documents since you're so smart. 
Q. Well, because we've tried to subpoena this 
doctor and he can't be found. That's why. 
A. Well, too bad for you then. I don't know. 
Page 578 
1 
Q. So maybe you haven't seen him quite as 
2 
often as you thought? 
3 
A. Bullshit. 
4 
Q. When was the last time you went then? 
5 
MR. EDWARDS: Watch your language, please. 
6 
THE WITNESS: Last year. 
7 
BY MR. LUTHER: 
8 
Q. That would be in '09. When in '09? 
9 
A. Beginning of '09. 
10 
't 
Q. You were asked to proclaim.", 
a an records from
11 
didn 
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A. When have I been asked to produce any records? 
Q. You've gotten several requests to produce 
in this case. They go to your lawyer. 
A. Okay. Well, I've beta there. So, what do you 
want me to say? 
Q. 
20 (Pages 575 to 578) 
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Page 579 
Q. Stop. We're staying will
2 
THE COURT REPORTER: One at a time. 
3 
BY MR. LUITIER: 
4 
Q. We're going to stay with 
5 
We're going to follow this down to, right to the 
6 
end. 
7 
A. Okay. Keep on going. 
8 
Q. So, you say you went to him in '09. Where 
9 
did you physically go to him? 
A. I physically went to his doctor's office. 
Q. On Okeechobee? I think you said it was at 
Simsbury and Okeechobee? 
A. Yes. 
Q. So, your testimony is in '09 you went 
physically into that office and saw him? 
A. It might have been end of '08 or '09. I can't 
tell you the date. I don't know the date. 
Q. And you haven't seen him since then, have 
you? 
A. No, I have not. 
Q. So, it's been at least a year —
A. Because I have enough —
Q. — 
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Page 581 
Q. Did somebody recommend this physician in 
Wellington to you? 
A. Yes. 
Q. Who did that? 
A. My friend Mark. 
Q. Mark who? 
A. I don't know his last name. 
Q. Where did you meet him? 
A. I don't know. 
Q. And did you pay for your first visit to 
that doctor? 
A. No. 
Q. Who paid for it? 
A. Mark. 
Q. Is he somebody you dated? 
A. Na 
Q. Is he someone with whom you had some kind 
of relationship? 
A. Yeah. 
Q. What kind of relationship did you have 
with him? 
Page 580 
1 
Q. How many pills do you have? 
2 
A. I don't know. I haven't counted them. I'm 
3 
sorry. 
4 
Q. And, and what kind of pills do you have? 
5 
A. What kind of pills? 
6 
7 
A
Q. 
. 
the drug? 
8 
Q. Okay. And 
was the drug you used to 
9 
abuse when you were teenager, didn't you? 
10 
A. Yes. I used to abuse them, yes. I don't 
11 
abuse them anymore. I lake them when I have panic 
12 
attacks. 
13 
Q. Were you ever addicted to MI ,
14 
A. No. 
15 
Q. And you haven't had to refill your 
16 
prescription, have you? 
17 
A. No. 
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is that right? 
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A. Nope. 
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Q. Now, what made — I want to clarify what 
22 
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made you go to see this doctor in Wellington? 
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A. Because my, I, I thought I was, something was 
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wromvith my heart. 
 
25 
Page 582 
1 
A. Our sons would play together. 
2 
Q. Do they still play together? 
3 
A. No. 
4 
Q. Was he a client of yours? 
5 
A. No. 
6 
Q. Do you know physically where this office 
7 
was that you went in Wellington? 
8 
A. I told you, no. You have just as a bad memory 
9 
as I do. 
10 
Q. Well, I'm old. Now, what invasion — what 
11 
do you mean when you say you've suffered invasion of 
12 
your privacy? 
13 
A. Are you serious? Well, here is one. Here is 
14 
two. 
15 
Q. 
16 
did —
17 
A. Investigators. 
Q. — in the public? 
A. All my damn, all these years that I've, after 
Jeffrey they wanted -- invasion of my privacy, are you 
kidding me? I can't go anywhere without anyone knowing 
where I'm going. The FBI, the investigators following 
me everywhere. I can't take my son out with anybody 
knowing me. 
Invasion of my privacy?. Everybody knows 
So, you're talking about things that you 
21 (Pages 579 to 582).
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PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by cynthia hopkins (601-051-976.2934) 
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Page 583 
1 
that Jeffrey Epstein molested me. So, if my son 
2 
wants to go out and play with somebody, oh, no, 
3 
she's the little girl that was in prostitution for 
4 
Jeffrey Epstein, so we don't want her playing with 
5 
our son. 
6 
Q. So, or do they say she's the lady that 
7 
runs her own escort service, we don't want her 
8 
playing with our son? 
9 
A. No one knows about that shit except you guys. 
10 
Q. How about when you were working for 
11 
another escort service? 
12 
A. How about what? 
13 
Q. You don't think anybody knew about that? 
14 
A. No. 
15 
Q. How about when you were —
16 
A. lam very discrete what I do. l don't put my . 
17 
name in the newspaper like Jeffrey Epstein saying that I 
18 
am a prostitute or a slave for Jeffrey Epstein. 
19 
Q. How about when you were top, dancing 
20 
topless at bars? Do you think maybe people said —
21 
A. 1 did that out of, like not locally. 
22 
Q. So, maybe, well, I mean —
23 
A. Well-
24 
Q. You wouldn't exactly call Platinum 
25 
A. Show Girls is in Boynton Beach Boulevard. I 
Page 585 
1 
all out. Everybody knows. Okay. You can sit there and 
2 
act like you, you can act like an attorney and --
3 
Q. Has the words —
4 
A. — say where has your name been? My name is 
5 
out there everywhere. Okay. I am the prostitute of 
6 
Jeffrey Epstein. I have brought young underaged girls 
7 
there. I am so horrible. 
8 
my son can't play with certain kids 
9 
because of Jeffrey Epstein now. He has ruined my 
10 
fucking life. He has brought me into this industry 
11 
that this is all I know. And now I can't even, I 
12 
can't even explain to you the hard things that I've 
13 
been through my life because of Jeffrey Epstein, 
14 
because he has taught me and many other girls how to 
15 
pull money from older men. 
16 
Q. Let's just be honest for the ladies and 
17 
gentleman of the jury: Ho didn't force you to do 
18 
anything? 
19 
A. But he taught me from a young age —
20 
Q. Wait a minute. Let me finish. 
21 
A. — when I was 13 years old. 
22 
Q. You --
23 
A. He taught me how to get money real quick. 
24 
Q. Do you — 
25 
A. — from an old man. Don't sit here and tell 
Page 584 
1 
live in West Palm. 
2 
Q. So, you meant within the immediate 
3 
geographic area. And maybe they said, well, this is 
the lady that goes and sells her wares at all these 
5 
topless bass; we don't want our children playing 
6 
with her. 
7 
A. No, not all. They see Jeffrey Epstein and my 
8 
name all over the place and they say, you know what, I 
9 
don't even want anything to with this girl because she 
10 
was a prostitute for Jeffrey Epstein. 
11 
Can 1 talk to him without you in his ear? 
12 
Ant I done talking? 
13 
Q. Could you just tell me one place where 
14 
your name has appeared anywhere as being someone who 
15 
saw Jeffrey Epstein? 
16 
A. It's everywhere. 
17 
Q. Well, where? Just tell me one place. 
18 
A. Where have you been? 
19 
Q. Just tell me one place. Can you cite 
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me — 
21 
A. Ifs in the newspaper. 
22 
Q. What newspaper ever ran your name? 
23 
A. The initials of my name? 
24 
Q. No, your name. 
25 
A. It doesn't matter. The 
means 
It's 
(561) 8 3 2-7 50 0 
Page 586 
1 
me that I was not forced or anything like that. 
2 
Q. That's exactly what I'm suggesting, ma'am. 
3 
Do you believe that you owe, that you have a certain 
4 
leVel of responsibility for your own conduct? 
5 
A. Now I do. 
6 
Q. You're 21 years old. 
7 
A. When I was 13 years old, 'didn't, I wasn't, 
8 
no, I did not have that demeanor. 
9 
Q. So, at 21 what you thought, because you 
10 
want to clean up your imagine for your son, right? 
11 
You want him to look up — 
12 
A. Yes, I do. 
13 
Q. So, as part of that process what you 
14 
thought you would do at 21 is you would agree to 
15 
hire out to strange men whom you don't know for 
16 
between $300 and $500 for what you say is to go sit 
17 
in rooms naked with them, and that's how you thought 
18 
you would prove? 
19 
A. Because that's all I know. I'm sorry. 
20 
Q. And Jeffrey Epstein didn't make you do 
21 
that, did he? You decided to do that, didn't you? 
22 
A. You know what 
23 
Q. A whole new business that you decided to 
24 
do on your own; is that right? 
25 
MR. EDWARDS: Object to form. 
22 (Pages 583 to 586) 
PROSE COURT REPORTING AGENCY,. INC. 
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Electronically signed by cynthia hopkins (601-051476-2934) 
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Page 587 
1 
THE WITNESS: — before 1 —
2 
MR. EDWARDS: Argumentative, asked and 
3 
answered. 
4 
BY MR. LUTTIER: 
5 
Q. Did Jeffrey Epstein ever give you the 
6 
business advice on a business plan to go out —
7 
A. Yes, he did. He gave me business advice. 
8 
Q. Wait. You started this in January? 
9 
A. You know what he told me this: He said, you 
10 
inc girls, this is business. Let's talk business, 
11 
I
.
 
You get me girls, twill pay you. Is that not 
12 
called business? 
13 
Q. So, and you quit doing that when? 
14 
A. You get me girls, and I brought him.two girls 
15 
a day, one girl a day, $200 each. That's not business? 
16 
Q. And when you —
17 
A. He taught me business and now I run business. 
18 
Q. And so —
19 
A. Just like you run business. 
20 
Q. And when did that, when did you start —
21 
A. Just like you learned how to do this, I 
22 
learned how to do this. 
23 
Q. What — so, you kamed to be a 
24 
prostitute? 
25 
A. Yes, I did. 
Page 588 
1 
Q. And you enjoy it? 
2 
A. No, 'don't enjoy it, and I can't wait to get 
3 
the hell out of it. 
4 
Q. And that's why in January of '010 you 
5 
decided what you would do is start getting men to 
pay you S300 to $500 an hour to sit around naked 
7 
with them, is that right? 
8 
MR. EDWARDS: Form. 
9 
THE WITNESS: Yes, that's right. 
10 
BY MR. LUTTIER: 
11 
Q. And the last time you took a girl to 
12 
Jeffrey Epstein was when? 
13 
THE WITNESS: Did we already ask this 
14 
question? 
15 
MR. LUTTIER: When? No, the last time —
16 
MR. EDWARDS: Object to the form. 
17 
MR. LUTTIER: — you said you went was —
18 
MR. CRITTON: You're out of time. 
19 
MR. LUTTIER: Okay. 
20 
THE VIDEOGRAPHER: Going off the record at 
21 
3:14 p.m. This is the end of Tape 2. 
22 
(A brief recess was held and 
23 
Mr. Goldberger did not re-enter the room.) 
24 
THE VIDEOGRAPHER: We're back on the 
25 
record at 3:24 p.m. This is the start of 
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Page 589 
Tape 3. 
MR. EDWARDS: Before we get started I just 
want to put something on the record that there 
was a hearing, I believe it was November 3rd, 
2009, and the judge suggested that the defense 
only have one attorney there. And his 
recommendation was such because of the 
breakdown —
MR. LUTT1ER: Well, let's —
MR. EDWARDS: — in the first deposition. 
You can, you can make a record after. That is 
fine. Was because of the breakdown in the 
first deposition, and he thought that that type 
of intimidation by more than one attorney would 
lead to an additional meltdown. 
We have been fine thus far today despite 
there at a minimum always being two attorneys 
and in the last 15 to 20 minutes not only was 
Mark Luttier here and Bob Critton as it has 
been all day, but Jack Goldberger was also in 
the room. 
And once it was lined up three attorneys 
over there, either passing notes, talking in 
each other's ear, and otherwise assisting in 
the deposition or at least that was the feeling 
Page 590 
1 
from the witness, we began to have another 
2 
meltdown. 
3 
So, hopefully we can proceed with less 
4 
attorneys and we can get through this process. 
s 
But I just wanted to put on the record exactly 
6 
who was in the room when everything started to 
7 
break down just now. 
8 
MIL LUTIIER: Well —
9 
MR. EDWARDS: If you have something to 
10 
say, that's fine. 
11 
MR. LUTHER: That just is not factually 
12 
correct. Mr., first of all the judge ordered 
13 
that Mr. Critton and I could be present 
14 
throughout this deposition. Mr. Critton and I 
15 
have been present throughout this deposition, 
16 
and he and I have communicated throughout the 
17 
deposition. 
18 
Mr. Goldberger walked in here. I didn't 
19 
put a stopwatch on how long he was there. He 
20 
is not even here now. He was here for maybe 
21 
ten minutes. I had no communication at all 
22 
with him. He carne. He sat here. He got up 
23 
and he walked out. 
24 
This breakdown that you're talking about 
25 
occurred Ions before Mr. Goldberger ever of 
(561) 832-7500 
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Page 591 
here. So, I dispute —
2 
THE WITNESS: No. 
3 
MR. LUTMER: — the facts, but it's sort 
4 
of a moot issue now anyway, so —
5 
MR. EDWARDS: But if we're going to get 
6 
into that, then every time he comes into the 
7 . 
room do we need to now put it on the record 
8 
that he is in the room? 
9 
MR. LUTTIER: I have absolutely no 
10 
problem —
11 
MR. EDWARDS: And each time —
12 
MR. LUTTIER: Anytime he comes in, we'll 
13 
stop him and well let him know he can't come 
14 
in here. Quite frankly, if you would have said 
15 
something to me about it, I was examining the 
16. 
witness, I would have stopped right then and 
17 
said, Jack, get out of the room. 
18 
MR. EDWARDS: And I know in all fairness 
19 
to what you just said I am not saying that to 
20 
you was not factually accurst; what you just 
21 
said, but you weren't able to see what was 
22 
behind you, the passing of the cellphone and 
23 
other things that the witnesses notices. 
24 
I am just telling you that this impacts 
25 
the deposition. So, i just want to make it 
Page 592 
1 
clear so that you would know exactly what's 
2 
happening and maybe we can get through this. 
3 
You know, it's all of our goals to get through 
4 
this day. So, I, I think the witnesses is 
5 
ready if you're ready, Mr. Luther. 
6 
MR. LUTTIER: I'm ready. 
7 
MR. EDWARDS: Okay. 
8 
MR. CRITTON: What time did we start 
9 
because we haven't 
we've been on the record, 
10 
but we haven't asked a single question. 
11 
THE VIDEOGRAPHER: It's 3:28 right now. 
12 
Three and a half minutes. 
13 
MR. CRTITON: Thank you. 
14 
BY MR. LUTTIER: 
15 
Q. I am now referring to your, your 
16 
interrogatory answers. These are answers that you 
17 
gave to written questions that were sent to you in 
18 
this case. And they are entitled Defendant's 
19 
unverified better answers to first interrogatories. 
20 
I believe they may have been marked as Exhibit 1 to 
21 
the first deposition, but there is only one set of 
22 
them. 
23 
• 
MR. LUTHER: And Brad, they are, the date 
24 
of service on, I don't know, wait. Date of 
25 
service is August 4th, 2009. 
Page 593 
1. 
MR EDWARDS: That's the —
2 
MR. LUTHER: Defendants unverified 
3 
better answers to first interrogatories to 
4 
Plaintiff. Later I'm going to come to the 
S 
Plaintiffs supplemental better answers to 
6 
Defendant's Interrogatory No. 19. 
7 
MR. EDWARDS: Okay. But you said the date 
8 
of service meaning you saved on us? 
9 
MR LUTTIER: No, no. Your answers, 
10 
better answers. 
11 
MR. EDWARDS: Got it. I am looking at the 
12 
same document you are. 
13 
BY MR. LUTTIER: 
14 
Q. All right. Ma'am, in response to some 
15 
interrogatories you stated that from the end of 2007 
16 
to November of 2008 you worked at Palm Beach Angels 
17 
earning S800 a week. So that would have been a 
18 
period of approximately one year; is that right? 
19 
MR. EDWARDS: Read. 
20 
TIDE WITNESS: On advice of counsel I am 
21 
invoking my Fifth Amendment rights again under 
22 
the United States Constitution. 
23 
BY MR. LUTHER: 
24 
Q. From, for the entire period of time that 
25 
you worked at Palm Beach Angels, what did you do for 
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Page 594 
your money? 
A. On advice of counsel I'm invoking my Fifth 
Amendment rights under the United States Constitution. 
Q. In continuing in answering that particular 
interrogatory you said that in 2008 you worked at 
Palm Beach Massage. Where is Palm Beach Massage 
located? 
A. On advice of counsel I'm invoking my Fifth 
Amendment rights under the United States Constitution. 
Q. What did you do at Palm Beach Massage? 
A. On advice of counsel I'm invoking my Fifth 
Amendment rights under the United States Constitution. 
Q. Did you have any communication with 
Jeffrey Epstein after the phone call you made to him 
following the FBI's interview of you? 
A. I talked to M. Oh, my God. I don't know 
what I am going through. I'm like shaking. 
Q. I am talking about now a conversation with 
Mr. Epstein. 
MR. EDWARDS: The question was, did you 
talk to him after you called him — 
MR. LUTTIER: Right. 
MR. EDWARDS: — after the FBI statement? 
MR. LUTTIER: Right 
24 (Pages 591 to 594) 
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Page 595 
BY MR. LUTTIER: 
2 
Q. And the date of your FBI statement for 
3 
your information was April 241h, 2007. Did you have 
4 
any conversation with Jeffrey Epstein after that 
. 
5 
date? 
6 
A. After I, after I had called my attorney? 
7 
Q. After April 24th, '07, which is the date 
8 
that you gave a st 
FBI. 
A. I talked toaalasic) 
or whatever her 
name is. 
Q. Did you have any conversation with Jeffrey 
Epstein? 
A. No. I don't think so, no. 
Q. Other than the witnesses you have listed 
in answer to Interrogatory No. 5, do you know of any 
other witnesses or do you intend to call any 
witnesses in the trial of this matter? 
A. What? 
MR. EDWARDS: Objection. Attorney-client 
privilege. I don't want her answering 
questions as to whether, as to information that 
she and I have spoken about in terms of what 
witnesses will be called at trial or our trial 
strategy. 
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Q. When did you last have communication with 
25 
him? 
Page 597 
with fl
out being a witness? That is what 
would he be offering as testimony in the case? 
A. What would he be offering? 
Q. Yeah. Why did you ask him about being a 
witness? 
A. I didn't ask him about being a witness. I 
.told hhn about what happened to me when I was 13 years 
old. 
Q. Okay. 
A. I'm not asking anybody to be a witness as of 
right now. 
Q. What's 
• 
A. I'm my own witness. 
MR. EDWARDS: Listen to his question. 
THE WITNESS: I am trying. I can't think 
right now. 
MR. EDWARDS: He wasn't asking you about 
being a witness. 
BY MR. WrITER: 
Q. Where does ...live 
now? 
A. West Palm Beach. 
AQ. 
t
Palm? 
Page 596 
1 
BY MR. LUTHER: 
2 
Q. Have you spoken to anyone with respect to 
3 
their willingness or your intention to call them as 
4 
a witness to the trial of this matter? 
5 
MR.. EDWARDS: Not who I have spoken to. 
6 
MR. LUTHER: Yeah, you. 
7 
THE WITNESS: What? 
8 
BY MR. LUTHER: 
9 
Q. Have you spoken to anybody about being a 
10 
witness' 
is matter? 
11 
A. 
12 
Q. Anyone else? 
13 
A. Not that I know of. 
14 
Q. And when did you speak with 
15 
about being a witness? 
16 
A. May `09. 
17 
Q. And what is it you told him or asked him 
18 
about being a witness? 
19 
A. I told him that Jeffrey Epstein molested me 
20 
since 1 was 13 years old. 
21 
Q. Okay. And he wasn't around at the time 
22 
that you alleged Mr. Epstein molested you, correct? 
23 
A. He wasn't around at the time when Jeffrey 
24 
Epstein was molesting me. 
25 
. Okay.  S
a
=
t
r w 
did you confer 
(561) 832-7500 
Page 598 
1 
A. January 3rd, 2010. 
• 
2 
Q. And for what purpose did you have 
3 
communication with him on that date? 
4 
A. I had to give him some of his clothes. 
5 
Q. When was 
' 
were in 
6 
' tion with 
that would be 
7
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
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24 
25 
A. lie's my son's father. So, I talked to him two 
weeks ago. 
Q. And where was he when you talked to him? 
A. Fort Myers. 
Q. And do you know how he's employed now? 
A. .No. He says he's not employed. 
Q. Have you discussed with him in the last 
year anything about this lawsuit? 
A. Yes. . 
Q. What have you discussed with him? 
A. I told him I'm going through a lawsuit. 
Q. And what did he say? 
A. He said okay. 
Q. Have you asked him to be a witness? 
A. No. 
other members of 
family in the last 
Q. Have you 
' 
nication with any . 
two years? 
25 (Pages 595 to 598) 
PROSE COURT REPORTING AGENCY 
INC. 
(561) 832-7506 
Electronically signed by cynthia hopkins (601.061-976.2934) 
Electronically signed by cynthia hopkins (601.051-976-2934) 
Electronically signed by Cynthia hopkins (601.051.976-2934) 
to5542lef-d2994e4t-gba6-135aad2714405 
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Page 599 
1 
A. Yes. 
2 
Q 
3 
A. 
.c). 
4 
Q. Who is 
5 
A. His sister. 
6 
Q. And where does she live? 
7 
A. Wellington. 
8 
Q. And for what purpose have you been in 
9 
touch with her? 
10 
A. She's my son's aunt 
11 
Q. And with what degree of frequency are you 
12 
in communication with her? 
13 
A. She asked me to attend her wedding via e-mail 
14 
this March of '010. 
15 
Q. Have you discussed with her anything about 
16 
Mr. Epstein? 
17 
A. No. 
18 
Q. Does she to the best of your knowledge 
H 
know anything about it? 
20 
A. Yes. 
21 
Q. Did you say no? 
22 
A. Yes. 
23 
Q. Does she know anything about? 
24 
A. Yes. 
25 
Q. What does she know about it? 
1 
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Page 601 
Q. Is that the last time she's seen your son? 
A. Approximately, yeah. 
Q. Who was watching your son when you were 
down at Spearmint Rhino's from 8:00 at night until 5 
in the morning? 
A. 
Q. I
sic) who you 
identified earlier? 
rather? 
A. Yeah. 
Q. And where was she watching him? 
A. At my house. 
Q. So, does she come spend the night at your 
house? 
A. Yes. 
Qa.gd there, was there ever a time that you 
and 1M lived together? 
A. Yes. 
Q. When was that? 
A. When we were 13, 14. 
Q. Thirteen and 14. Was any adult living 
with you? 
A. My father. 
Q. Since you were 13 or 14 has a 
ever 
lived with you? 
ANo. 
Page 600 
A. That Jeffrey Epstein's a child molester. 
2 
Q. And how did she get that information? 
3 
A. From the news, from friends, from the 
4 
neighborhood --
5 
Q. Did —
6 
A. From her brother. 
7 
Q. — has she asked you any questions about 
8 
your relationship or interaction with Mr. Epstein? 
9 
A. She said I am sorry that you're going through 
10 
the trauma that you're going through. 
12 
other member of 
family? 
Q. Have you
communication with any 
11 
13 
A Ms mother. 
14 
Q. 
is her name? 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
AI 
Q. And where is she located? 
A. Fort Myers. 
Q: And when did you last have communication 
with her? 
A. I don't know. A year ago. 
Q. And for what purpose did you have 
communication with her at that time? 
A. Dropping my son off with her. 
Q. In Fort Myers? 
A. Belle Glade.  
(561) 832-7500 
1 
2 
3 
7 
8 
9 
10 
11. 
12 
13. 
14 
15 
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23. 
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Page 602 
Q. Did you tell 
why you needed 
to have her watch your son all night when you were 
down at Spearmint Rhino's? 
A. I told her I need to work. 
Q. Do you tell her what you do for work? 
A. Yes. 
Q. What did you tell her? 
A. I sell lingerie and shoes and purses and Mary 
Kay. 
Q. Do you have any personal knowledge of the 
matters about which the witnesses listed in your 
answers to interrogatories that these witnesses 
have, have information about? 
MR. EDWARDS: Objection, attorney-client 
privilege. And we do this all the time. 
BY MR. LUITIER: 
Q. This is just a list as prepared by your 
lawyer. You don't know what any one of these 
witnesses would say? 
MR. EDWARDS: And if she does, it's going 
to be information that I have talked to her 
about which you know is protected by 
attorney-client privilege and so do L 
If you're asking her independent of her 
information I have told her, fine. 
26 (Pages 599 to 602) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by cynthia hopkins (601-061-976-2934) 
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Page 603 
1 
MR. LUTTIER: That's exactly what I am 
2 
asking her. 
3 
MR. EDWARDS: Okay. Let's ask it that way 
4 
because it doesn't sound like that. 
5 
BY MR. LUTTIER: 
6 
Q Do you know of any information that these 
7 
witnesses have based on your communications with 
8 
them? 
9 
A. Excise me? 
10 
Q. Do you know any information that any of 
11 
these witnesses have about this case based on your 
12 
personal contact with them? 
13 
A. What witnesses? 
14 
Q. That are listed in the Answers to 
15 
Interrogatory 5. 
16 
MR. EDWARDS: Just answer his question, 
17 
yes or no. 
18 
THE WITNESS: No. I don't know these 
19 
people. 
20 
BY MR. LUTTIER: 
21 
Q. On any visit that you went to see Jeffrey 
22 
Epstein, did he ever ask you to do anything that you 
23 
said you did not want to do? 
24 
A. Yes. 
25 
Q. What did he ask you to do that you said 
Page 604 
1 
you didn't want to do? 
2 
k 
At one occasion he wanted to stick his fingers 
3 
like all the way inside of me and I said no? 
4 
Q. And what did he then do when you said no. 
5 
A. He said okay. So then he just penetrated my 
6 
vagina with his fingers. 
7 
Q. What did he, did he —when you said you 
8 
didn't want him to do that, did he respect your 
9 
wishes and not do it? 
10 
A. No. Actually he, he pushed it. He tried to 
11 
do it and he said, okay, no, it's going to be okay. 
12 
It's going to be okay. And I backed off and I said no. 
13 
Q. And then he stopped? 
14 
A. Then he decided to respect my wishes. 
15 
Q. Okay. Any other — and this is on one 
16 
occasion? 
17 
A. Many occasions. 
18 
Q. Well, on — so on many occasions he would 
19 
say he wanted to penetrate your vagina. You would 
20 
say you didn't want — well, actually what you said 
21 
was he wanted to penetrate your vagina deeply I 
22 
think. And, and you said no and he respected your 
23 
wishes and didn't do it? 
24 
A. Correct. 
25 
Q. Okay. Was there ever anytWnthatt at 
Page 605 
1 
all that you said I don't want to do this and Jeff 
2 
said you had to do it anyway? 
3 
A. Yeah. I told him that at times I did not want 
4 
to bring girls, and he says, yes, I want you to do it 
5 
anyway; you need to do it anyway. 
6 
Q. And did you tell all the girls that you 
7 
brought that Jeffrey would respect their wishes, and 
8 
if they were uncomfortable doing anything, that they 
9 
should just tell him that, and he wouldn't ask them 
10 
to do anything that they weren't comfortable doing? 
11 
A. Yes, because I was scared. 
12 
Q. And that's, in fact, how he treated you, 
13 
fir? 
14 
A. Yes. 
15 
Q. You previously earned a degree as an 
16 
esthetician; is that right? 
17 
A. Yes. 
18 
Q. And you now earned a define since going to 
19 
Mr. Epstein in massage therapy, correct? 
20 
A. Yes. 
21. 
Q. And you earned both of those from the same 
22 
school located on Northiake Boulevard? 
23 
A. Yes. 
24 
Q. And you could pursue a profession as an 
25 
esthetician, a massage therapist if you so chose, 
1 
2 
3 
4 
5 
6 
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(561) 832-7500 
PROSE COURT REPORTING 
Page 606 
could you not? 
A. No, not as a massage therapist. 
Q. Why not? 
A. Because I've told you once before I need to 
take the nationals. 
Q. But no one has prevented you from taking 
test, right? 
A. I have to wait to take the test. It only 
happens twice a year. 
Q. And has — did you pass the first 
opportunity you had? 
A. No. 
Q. Okay. So, when's, when's the test coming 
up? 
A. In a few months. 
Q. And are you going to take it? 
A. Yes. 
Q. And you could have been working as an 
esthetician ever since you went to Jeffrey 
Epstein's? 
A. And I did work as an esthetician. 
Q. No one has prevented you from doing that, 
corned? 
A. No. 
9. You made the decision to drop out of 
 
27 ( Pages 603 to 606) 
AGENCY, INC. 
(561) 832-7506 
new:ironically signed by cynthia hopkins (601.051-976-2934) 
Electronically signed by cynthia hopkins (601-061-976-2934) 
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bSS42fet-d299-4e41-9ba6-85aad27f4405 
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Page 607 
school before you ever met Jeffrey Epstein, did you 
1 
2 
not? 
2 
3 
A. I'm pretty sure I was going to school when I 
3 
Was seeing Jeffrey Epstein. 
4 
5 
Q. But, but you made the decision to drop out 
5 
6 
based on other facts and circumstances that had 
6 
7 
nothing to do with seeing Jeff Epstein; isn't that 
7 
a 
correct? 
9 
A. Excuse me? 
9 
10 
Q. You decided to drop out of school for your 
10 
11 
own reasons particularly 1 think you said because 
11 
12 
you got pregnant, didn't you? 
12 
13 
A. No. 
13 
14 
Q. Well, why did you decide to drop out of 
14 
15 
school? 
15 
16 
A. I was trying to find girls to bring to 
16 
17 
Jeffrey's house. 
17 
18 
Q. Well, didn't you tell us the last 
18 
19 
deposition that you dropped out when you got 
19 
20 
pregnant? 
20 
21 
A. I was going to school when I was pregnant. 
21 
22 
Q. Yeah. And then you dropped out, right? 
22 
23 
A. I dropped out when I was four months pregnant. 
23 
24 
Q. Why did you drop out of Palm Beach 
24 
25 
Community School and then go to Pace school? 
25 
Page 609 
six. But then I did go back and I got my high school 
diploma, and like you said I have two degrees. 
Q. When did you get your, your GED? 
A. Yes. 
Q. When did you get that? 
A. When I turned 18. 
Q. And who did you get that from? 
A. The Adult Education Center. 
Q. So, you got a high school equivalency 
diploma at the same time you would have gotten a 
high school graduation certificate —
A. Correct. 
Q. -- had you stayed in school? 
A. Correct. 
Q. And then you were free to pursue the same 
pursuits as anybody else that had graduated from 
high school whether that would be college or a trade 
school or whatever you want to? 
A. No, no. If I would have stayed in school, I 
could have got some type of scholarship. I could have 
had many opportunities in school to learn higher 
education than just the GED. 
Q. Well, when you got —
A. And I could have — traveled and I could have 
went to a college, a bigger college, a state college. 
Page 608 
1 
A. Because ever since I met Jeffrey I - before 
2 
Jeffrey I made wonderful grades. And then ever since I 
3 
met Jeffrey my grades went down and I was failing. so I 
4 
had to go to a school to bring my grades backup. 
S 
Q. But you opted to drop out of the Pace 
6 
school before you graduated? 
7 
A. Yes. I was four months pregnant 
8 
Q. And that's why you dropped out? 
9 
A. Well, I needed to make money to buy a house, a 
10 
trailer so I could have my baby. 
11 
Q. Because you were pregnant? 
12 
A. Yes. 
13 
Q. Had you not been pregnant, you would have 
14 
continued in school, correct? 
15 
A. I can't answer that question. I don't know. 
16 
Q. Well, the point is the direct reason why 
17 
you dropped out was you were pregnant? 
18 
A. And I was making so much money off of Jeffrey 
19 
that I didn't think school was so necessary at that 
20 
time. 
21 
Q. Did you consult with your parents or any 
22 
counselors about that? 
23 
A. I didn't tell my parents about Jeffrey. 
24 
Q. How much were you making at that time? 
25 
A. I was making $200 pretty much a day or 400 or 
Page 610 
1 
Q. How do you know that? 
2 
A. It's common sense. 
3 
Q. Well, you don't know what your grades 
4 
would have been, right? 
5 
A. No, I don't know what my grades would have 
6 
been. 
7 
Q. And at — 
A. Do you know what tomorrow is going to bring? 
9 
Q. At the time that you went into the Pace 
10 
school, you were practically failing, weren't you? 
11 
A. Yeah, but Pace, they help girls, young girls 
12 
bring up their grades so you can go back into high 
13 
school and accomplish making more, bettering your grades 
14 
so you can get a scholarship. 
15 
Q. Well, in fact you got a scholarship for 
16 
your massage therapy, didn't you? 
17 
A. No. How could I7 
18 
Q. Did you tell us in the last deposition 
19 
that you got some kind of scholarship for going 
20 
there? 
21 
A. I didn't get a scholarship for going. No. 
22 
I've never got a scholarship. 
23 
Q. Did they lend you money to go to school 
24 
there? 
25 
A. For massage therapy but not for esthetics. 
(561) 832-7500 
28 (Pages 607 to 610) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by cynthia hopkins (601-051.976-2934) 
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Page 611 
Q. That's what I was talking about was 
2 
massage therapy. 
A. That's not a scholarship. 
Q. Okay. 
• 
A. That's a loan that I have to still payback. 
Q. Did you ever travel anyplace with Jeffrey 
Epstein? 
A Nope. 
Q. Are you — you're a person that uses the 
computer now, correct? 
A. Yep. 
Q. Did you ever communicate with Jeff Epstein 
on the computer? 
A. No, not that I real
Q. Who is 
(phonetic)? 
A. A boyfriend that I had when I was younger. 
Q. And when was he your boyfriend? 
A. I think I was 
Q. Was he beforein 
A. No. 
Q Was he after? 
A. 
, no. MM., 
he was before 
Yes 
Q. And was
 your boyfriend before you 
saw Jeff Epstein? 
Page 612 
A. Yes. 
2 
. And did you have sexual relations with 
3 
4 
A. I was younger when, when I dated. 
I was — 
Q. Thirteen? 
A. I think I just tinned 13. 
Q. _And
 you have sexual relations with 
Mr. 
A. No. 
Q. Well, you filed a better answers to 
Interrogatory 19 which asked you to identify all 
persons with whom you were sexually involved from 
age ten through September 2005. And one of the 
people you put was 
A. Okay. I'm sorry. I never had sex with 
Q. Did you have some kind of sexual activity 
with him? 
A. No, we 'list kissed. 
Q. Who is 
A. He lived off Drexel when I was living on 
Drexel. 
Q. Was he your boyfriend at one time? 
25 
A. No. 
(561) 832-7500 
17 
18 
19 
20 
21 
22 
23 
24 
25 
ua 
Page 613 
1 
Q. Did you have sex with him? 
2 
A. Yes. 
3 
Q. When? 
4 
A. The times I was seeing Jeffrey. 
5 
Q. Say when? 
6 
A. The time —
7 
Q. While you were seeing Jeffrey? 
8 
A. Yes. 
9 
Q. And... 
is, was, is a former 
10 
boyfriend of yours? 
11 
A. Yes. 
12 
Q. Had sex with him obviously, right? 
13 
A. Yes. 
14 
Q And that was after? 
15 
A. Yes. 
16 
Q. And
, another boyfriend of 
17 
yours with whom you had sex? 
18 
A. Yes. 
19 
Q. You had sex with 
while you were 
20 
seeing Jeffrey Epstein? 
21 
A. No, no. I don't know. I don't know. 
22 
Q. Well, you were having sex with at least 
23 
four people while you i
s Jeffrey 
24 
Epstein 
2 
3 
4 
5 
6 
7 
8 
11 
12 
13 
14 
A. Yes. 
MR. EDWARDS: Object to the form. 
BY MR. LUTTD3R: 
Q. And you weren't having any, during that 
whole period you weren't having sex with 
Mr. Epstein; you were just doing the massages —
A Yes. 
Q. — aSOP 
sexual acts wit 
to actually en 
MR. EDWARDS: Object to the form. 
BY MR. LUITIER: 
Q. Did you engage in both sexual ' 
and oral sex with esci of the indjvi 
Page 614 
A. Just intercourse. 
Q. No oral sex with any of those individuals? 
A. Name the 
I will tell you. 
Q. 
A. Yes. 
Q I think you already told us yes. And by 
way when you say oral sex, is that both giving and' 
receiving? 
A. Giving. 
29 (Pages 611 to 614) 
PROSE COURT REPORTING AGENCY,' INC'. 
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Electronically signed by cynthia hopkins (601-051.976.2934) 
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Page 615 
Q Giving. You didn't receive any oral sex 
from
A. 
Q. 
A. Yes, both. 
Q. Both? 
A. Give
t
Q• may
A. sis
?
A. Intercourse. 
Q. No oral? 
A. No. 
Q. 
v of those individuals Mr. 
his brother 
or 
ever perform any sexual act on you that 
you didn't want them to perform on you? 
A. No.
Q. Ii 
or 
ever perform 
any sexual act on you that you d" ft want them to 
perform on you? 
A. No, it was consensual. 
Q. And was your sex within 
both 
sexual intercourse as well as oral sex? 
A. Yes. 
Page 617 
1 
mean in particular? 
2 
MR. EDWARDS: Form. 
3 
THE WITNESS: Let's just say his cock was 
4 
as big as Jeffrey's. 
5 
BY MR. LUTTIER: 
6 
Q. That would be an indication of size or 
7 
lack of size? 
8 
A. Lack of size. Thanks for making me laugh. 
9 
Q. Are you on any prescription medication 
10 
now? 
11 
A. No. 
12 
Q. You testified in your last deposition that 
13 
you had participated in making some kind of a tape 
14 
in which you were engaged in sexual activities. Do 
15 
you recall that? 
16 
A. Yes. 
17 
Q. What, what, with whom did you make that 
18 
tape? 
19 
A. 
20 
Q. And when was that made? 
21 
A. '07. 
22 
Q. After Mr. Epstein? 
23 
A. Yes. 
24 
Q. Couple years after Mr. Epstein? 
25 
A. Yes. 
Page 616 
Q. And how about with •=7 
2 
A. Yes. 
3 
Q. 
w here along the line after that 
you met 
A. Yes. 
Q. Where did you meet him? 
A. I Imewthirn fora while but I met him like 
January of'09 in Cheetah's nightclub. 
Q. And why were you in, in Cheetah night club 
in January of'09? 
A. Hanging out. 
Q. Were you dancing? 
A. No. 
Q. What was he doing there? 
A. Hanging out. 
Q. And, and you had sexual intercourse with 
him. Did you have oral sex with him? 
A. Yes. 
Q. Was the sex good? 
MR. EDWARDS: Object to the form. 
THE WITNESS: No. 
MR. LUTTIER: Huh? 
THE WITNESS: No. 
BY MR. LUTTIER: 
Q. And when you say no what, what do you 
(561) 832-7500 
Page 618 
1 
Q. And what was depicted on the tape? 
2 
A. Just him and I having sex, oral sex, 
3 
intercourse, dancing, fun, fun, fun. 
4 
Q. And where was it made? 
5 
A. In the house that we lived together. 
6 
Q. And whose idea was it to make it? 
7 
A. Both of us. 
8 
Q And did a third party film it --
9 
A. No. 
10 
Q. — or did you set up a tripod? 
11 
A. I set up a camera. 
12 
Q. And what happened to the tape? 
13 
A. I deleted 
14 
Q. Did anybody see the tape? 
15 
A. No. 
16 
Q. You didn't show it to anybody? 
17 
A. I might have. I might have showed to M. but 
18 
Ideal think she cared to see it. 
19 
Q. Well, you infer* embarrassed about it, 
20 
were you? 
21 
A. No. 
22 
Q. You are, you are, would you say 
23 
comfortable with your body? 
24 
A. I guess I have to be ifl am in this industry, 
25,  
right? 
30 (Pages 615 to 618) 
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Electronically signed by cynthia hopkins (601-051-976-2934) 
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O.,  What's called a Marchnien Act 
Page 619 
1 
Q. Well, I mean being naked doesn't offend 
2 
you? 
3 
A. Yeah, it does. 
4 
Q. It does offend you? 
5 
A. Yeah 
6 
Q. Well, what percentage of your time when 
7 
you're working with your business did you spend 
8 
being naked? 
9 
A. A lot. 
10 
Q. But you choose to do it? 
11 
A. Yeah. 
12 
Q. You have been the victim of acts of 
13 
domestic violence, have you not? 
14 
A. Yes. 
15 
Q. When was the first time you were the 
16 
victim of an act of domestic violence? 
17 
A. With .M= 
I told you that 
18 
THE COURT REPORTER: Pm sorry? 
19 
THE WITNESS: With 
20 
BY MR. LUTTIER: 
21 
Q. Were you only a victim of domestic 
22 
violence on one occasion with Mr. 
23 
A. Yes. I was a victim, yes. 
24 
Q. And that was the first time that you had 
25 
ever been a victim of domestic violence? 
Page 621 
1 
BY MR. WITTER: 
2 
Q. Did you she ever approach you about that? 
3 
A. No. 
4 
Q. Did she ever tell the police she was 
5 
concerned about that? 
6 
A. No. 
7 
MR. EDWARDS: Object to the form. 
8 
BY MR. LUTTIER: 
9 
Q. Was your mother concerned that you were 
10 
sexually active at an early age? 
11 
MR. EDWARDS: Form, predicate. 
12 
MR. CRITTON: What's the form? 
13 
THE WITNESS: She was probably concerned 
14 
MR. EDWARDS: You're asking —
15 
MR. LUTTIER: Was your mother —
16 
MR. EDWARDS: You're asking 
to tell 
17 
you whether she knows how her mother was 
18 
feeling at some certain time. 
19 
BY MR. LUTTIER: 
20 
Q. The question stands. Was your mother ever 
21 
concerned that you were sexually active at an early 
22 
age? 
23 
MR. EDWARDS: Same objection. 
24 
THE WITNESS: She probably was concerned, 
25 
Yeah 
Page 620 
1 
A. Yes. 
2 
Q. Do you know of-(phonetic)? 
3 
A. Yeah. 
4 
Q. Who is that? 
5 
A. It's actually my sister's son or daughter's 
6 
father's cousin. 
7 
Q. Sister's daughter? Your sister has a 
daughter? 
A. Yes. 
Q. So 
daughter's cousin's father? 
A. 
y's father, his cousin. 
a
cikay. When did you first meet 
A. Probably knew him since I was 11. 
Q. And did your mother express to you 
concerns as early as February of '03 that you were 
sexually active with him? 
A. I was never sexually active with him. 
Q. Did your mother believe that you were? 
MR. EDWARDS: Object to the form. 
BY MR. LUTTIER: 
Q. Do you know? 
MR. EDWARDS: Predicate. 
THE WITNESS: No. 
Page 622 
1 
BY MR. LUTTD3R: 
2 
Q. Why? 
3 
A. Who would want there daughter being sexually 
4 
active at a young age? 
5 
Q. What gave her that concern? What 
6 
activities were you engaging in to give her that 
7 
concern? 
8 
MR. EDWARDS: Object to the form, 
9 
predicate. 
10 
THE WITNESS: A mother's love. I don't 
11 
know. I can't speak for my mother. I am 
12 
sorry. 
13 
BY MR. LUTTIER: 
14 
Q. Were you doing something that gave her 
15 
that concern? 
16 
MR. EDWARDS: Object to the form, 
17 
speculation. 
18 
THE WITNESS: I don't know. 
19 
BY MR. LUTHER: 
20 
Q. Are you aware of the fact that your father 
21 
filed a Petition for Involuntary Treatment for 
22 
Substance Abuse with respect to you back in July of 
23 
'04? 
24 
A. He filed for what? 
(561) 832-7500 
31 (Pages 619 to 622) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by cynthia hopkIns (601.051.976.2934) 
Electronically signed by cynthla bodkins (601.051.976-2934) 
Electronically signed by cynthia hopkIns (601-051-976-2934) 
b55421et-d299-4e41-9ba6-85aad2714405 
EFTA01108882

Page 623 
Petition for Involuntary Treatment for Substance 
2 
Abuse. 
3 
A. I never went to any program or anything. 
4 
Q Yeah, but do you know he filed a petition 
5 
in the court claiming that you come home when you 
6 
want to, you're in trouble with the police, and that 
7 
you're taking Xanax, cocaine, and alcohol? Did you 
8 
know he filed that in July of '04? 
9 
A. No. 
10 
Q. You didn't know that? 
11 
A. (Witness shakes head.) 
12 
Q. Were you, in fact, taking Xanax, cocaine, 
13 
and alcohol in July of '04? 
14 
A. Yes. I apologized to my father. 
15 
Q So, he had a legitimate concern at that 
16 
time? 
17 
MX. EDWARDS: Form. 
18 
THE WITNESS: Yes. 
19 
BY MR. LUTHER: 
20 
Q. And with what degree were you taking 
21 
cocaine and alcohol at that time? 
22 
A. I was a confused little girl with Jeffrey 
23 
Epstein and that always, leaving Jeffrey Epstein's house 
24 
always lead me to do more drugs and more drugs. I was 
25 
uncomfortable about my body. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
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Page 624 
Q. What were you — 
A. I didn't like the way Jeffrey made me feel. 
Q. What were you uncomfortable about your 
body about? 
A. I felt insulted. I felt used. 
Q. Did you tell him that? 
A. No. 
Q. Did you tell anybody that? 
A Yeah. 
Q. Who did you tell? 
A. 
Q. On the, on the way over to Jeffrey 
Epstein's when you were taking her there? 
A. Yeah. We would tell each other that we didnt 
like the way we felt. 
Q. Did tu file a complaint that your 
boyfriend 
was stalking you? 
A. Yes. 
Q. Was be, in fact, stalking you? 
A. He got he was on coke one day, and I was 
scaled because he was trying to get in the house and 1 
didn't want nothing to do with him. 
Q. Did that 'five you some concern? 
A. Excuse me? 
Q. Did that give you concern? 
(561) 832-7500 
1 
2 
3 
4 
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9 
10 
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Page 625 
A Concern? 
Q. Yeah. I mean were you afraid? 
A. Only for that one night that he was on coke. 
He was just trying to, like, get in my house and I 
didn't want him in there. 
Q. Do you know a lady by the name of 
Jacqueline Miler? 
A Yeah. 
Q. How do you know Jacqueline Miller? 
A. Oh, my. I know her through T.J. 
Q. Who is T.J.? 
A. A friend of mine. 
Q. Where did you meet T.J.? 
A. Through Jacqueline Miller's boyfriend. 
Q. And who's Jacqueline Miler's boyfriend? 
MR. EDWARDS: Did you have a question, 
Bob? 
MR. CRITTON: He was telling me to ask her 
what T.J.'s — 
MR. EDWARDS: Oh, sony — 
MR. WITIER: 
full name is. We'll get 
to that. 
MR. EDWARDS: Okay. 
THE WITNESS: I don't — oh, God, I don't 
remember his name but they were both no good. 
Page 626 
1 
They were like gang members. 
2 
BY MR. LUTHER: 
3 
Q. That is T.J.? • 
4 
A. No, Jacqueline and her boyfriend. 
5 
Q. Okay. But you don't remember the 
6 
boyfriends's name? How did you — what was your 
7 
relationship with Jacqueline Miller? 
B 
A. Associates. We talked once in a while. 
9 
Q. When did you first meet her? 
10 
A. In — I don't know. Maybe when I was 14. 
11 
Q. Did she live in your neighborhood? 
12 
A. No. 
13 
Q. How did you meet her? 
14 
A I'm not sure. 
15 
Q. Was she a friend? 
16 
A. She became an associate. 
17 
Q. Is there a difference between an associate 
18 
and a friend? 
19 
A. Yeah. A friend is someone who's always by 
20 
your side and who you can talk to daily, and an 
23. 
associate is just someone you can, that you know. 
22 
Q. Did you socialize with her? 
23 
A. Yeah. 
24 
Q. What kinds of things did you do with her? 
25 
A. Not good things. 
32 (Pages 623 to 626) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051.976-2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
8584254441299-444,4488-88•882744408 
EFTA01108883

Q. 
Page 627 
What things? 
2 
A. We did, we did coke together. 
3 
Q. Who provided the coke? 
4 
A. She did. 
5 
Q. And anything else that you did with her? 
6 
A. Just drugs. 
7 
Q. What other drugs? 
A. Coke and pills. 
9 
Q. Who provided the pills? 
10 
A. She did. 
11 
Q. And this was during the time that you were 
12 
seeing Mr. Epstein? 
13 
A. Yeah. 
14 
Q. What else did you and she do together? 
15 
A. Nothing. 
16 
Q. Did you-all live together at some point? 
17 
A. I asked her to -- she asked me if she could 
18 
room with me when I was living in my trailer and I gave 
19 
her a chance. About a week later I found out that she 
20 
was not the kind of friend for me at all and she was 
21 
into no good things. And I have a son so I couldn't 
22 
have her around. 
23 
Q. What do you mean she was into no good 
24 
things? 
25 
A. She was into drugs and stealing and --
Page 629 
1 
A. Yeah. 
2 
Q. And she threatened to kill you? 
3 
A. Yeah, she threatened a lot of stuff. 
4 
Q. And did you believe she had the capacity 
5 
to do that? 
6 
A. No. 
7 
Q. What gang was she in? 
8 
A. Folk (phonetic). 
9 
Q. And did you know her to be a violent 
10 
person? 
11 
A. Yeah. But she's like 80-pounds soaking wet so 
12 
I'm not worried about her. She's just lost and God 
13 
bless her soul. 
14 
Q. Now, let's talk about Mr., is it =or 
15 
Redell (phonetic)? 
16 
A. 
17 
Q. 
And you have described earlier a 
18 
confrontation that you had with him. And was his 
19 
mother present for that confrontation? 
20 
A. Yes. 
21 
Q. And, and did it initially start out that 
22 
Mr.thr 
was physically abusive towards his 
23 
mo 
24 
A. Yes. I had told him to leave and his mother 
25 
came to pick up his daughter from my house. When she 
Page 628 
1 
Q. Did you and she have a physical 
2 
confrontation? 
3 
A. She brought -- I told her when she moved in 
4 
for that one week I told her do not bring anyone into 
5 
this house. She brought a man into my house. I opened 
6 
her bedroom door, found her giving him oral sex. I got 
7 
angry. I said, please leave. She was on drugs. 
8 
She got angrier and came into the bathroom 
9 
and hit me or tried to hit me on my head. So, I 
10 
pretty much held her down until the cops came 
11 
because I called the cops to get her out. 
12 
Q. Was it an upsetting event to you? 
13 
A. No. !just couldn't wait for her to get out. 
14 
Q. Was that a common thing for you to have 
15 
fistfights with other women? 
16 
A. No. I didn't throw a fist. No, it was not a 
17 
common thing. 
18 
Q. And did she threaten you on the way out? 
19 
A. Yes. 
20 
Q. And you said she was in a gang? 
21 
A. Yeah. 
22 
Q. And what did she tell you on the way out? 
23 
' A. 06,1 don't remember. I'm going to regret it. 
24 
Q. Well, did she say, I am going to get you, 
25 
bitch? 
'
rarat===alllarACISSIIIBAL.,
Page 630 
1 
arrived, he started pushing and shoving his mother into 
2 
the car. I could tell that he was on drugs. So, I said 
3 
this is uncalled, uncalled for. I called the cops and 
4 
that was that. He ran. I guess you can say I have a 
5 
good heart and I give the wrong people chances. 
6 
Q. Well, that was one incident when, when the 
7 
mother was present, right? 
8 
A. Yes, and that night actually --
9 
Q. There was a second incident, was there 
10 
not? 
11 
A. Yes. That night he — that's when he pushed 
12 
me down a couple times and that's when I hit him and 
13 
then he spit blood all over the house. And that's when 
14 
Er, DCF got involved. So, I, three days later, 
15 
immediately moved out of the house and moved to Royal 
16 
Palm. And the next thing I know the week that I moved 
17 
to Royal Palm, he showed up at my house. 
18 
Q. Okay. Well, let's go through this slowly. 
19 
The first confrontation where his mother was 
20 
involved happened in November of '06; is that right? 
21. 
A. If that's what the document says. 
22 
Q. Okay. And that's when he was pushing his 
23 
mother around and, and then he turned towards you 
24 
and pushed you around, right? 
25 
A. Yeah. 
(561) B32-7500 
33 (Pages 627 to 630) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia honker's (601.051.976-2934) 
Electronically signed by cynthia honker's (601-051-976-2934) 
b5542lef-d299-4e4f-94,36-85aad27f4405 
EFTA01108884

Page 631 
1 
Q. Now, the second time there was a 
2 
confrontation was March 10th of'07? 
3 
A. Yes. 
4 
Q And at that time that's when you got into, . 
5 
what, was there, was there another incident the 
6 
evening of November '06 before we got to March of 
7 
'07? 
8 
A. Yeah. That's when he pushed me down. 
9 
AL Okay. Then in March of'07, Mr. 
.10 
=smacked you and choked you, interne? 
11 
A. Yes. Well, l moved specifically benuse of 
12 
him. I didn't want him in my life at all. And he found 
13 
out where I lived and he came to my residence, kicked 
14 
down the door and smacked me and choked me, yes. 
15 
Q. And, in fact, you filed for an injunction 
16 
against domestic violence on March 14th, '07, 
17 
against him, did you not? 
18 
A. Yes. 
19 
Q. And you claimed that you and he were 
20 
together for about six months, right? 
21 
A. Yes. 
22 
Q. He had problems with cocaine? 
23 
A. Yes. 
24 
Q. And then you and he took a break for a 
25 
couple of months, right? 
Page 633 
1 
A. Yes. 
2 
Q. And then he smashed glass all over your 
3 
house, right? 
4 
A. Yes. 
Q. And then he took his fist and he hit you 
6 
across the left side of your face, right? 
7 
A. Yes. 
8 
Q. And then your mother came and he picked 
9 
her up and threw her across the kitchen, didn't he? 
10 
A. Yes. 
11 
Q. And then he smacked your roommate in the 
12 
face and threw her into the wall, is that right? 
13 
A. Yes. 
14 
Q. Was all of that traumatic to you? 
15 
A. That night. 
16 
Q. And you represented to the court under 
17 
oath that you feared for your life; is that right? 
18 
A. Yes. 
19 
Q. And you were very scared of him? 
20 
A. Yes. 
21 
Q. And he damaged you and your son. You felt 
22 
that both of you were in jeopardy; is that right? 
23 
A. Yes. 
24 
Q. And he also had knives and he told you he 
25 
had a gun in addition; is that right? 
1 
A. Yes. 
2 
Q. And then you got back toge 
3 
right? 
4 
A. Yes. 
5 
Q And you had peat intimacy 
6 
words, right? 
7 
A. Okay. 
8 
Q. But that he was very jealou 
9 
A. Yes. 
10 • 
Q. Is that accurate? 
11 
A. Yes. 
12 
Q. And you also said that on 
13 . 
he got very violent He was  
14 
wouldn't let you get off your bed. 
15 
that? 
16 
A. Yes. 
17 
Q. He wouldn't let you get to 
18 
would he? 
19 
A. Correct. 
20. 
Q. And when you went into 
21 
living room he grabbed you by yo 
22 
you back into your bedroom. Doy 
23 
A. Yes. 
24 
Q. And then he slammed you 
25 
several occasions, correct? 
Page 632 
ther again, 
to use your 
s. 
March 10th, '07, 
restrainingyou, and he 
Do you remember 
our phone, 
the room, in the 
r neck and dragged 
ou remember that? 
on the bed on 
(561) 832-7500 
Page 634 
1 
A. Yes. 
2 
MR. LUTHER: Let's mark this as our next, 
3 
whatever number we're on. 
4 
THE COURT REPORTER: Five. 
5 
MR. LUTTIER: Five. 
6 
(Defendants Exhibit No. 5 was marked for 
7 
identification) 
8 
BY MR. LUITIER: 
9 
Q. Let me show you what is now marked as 
10 
Exhibit Sand ask you if that's a copy of the 
11 
Petition for Injunction Against Domestic Violence 
12 
that you filed? Is that your signature on that 
13 
Petition.for Injunction Against Domestic Violence? 
14 
A. Yes. 
15 
Q. Now, this injunction references two 
16 
incidences, one dated November 23rd, '06 and one 
17 
dated March 1011), '07, right? 
18 
MR. EDWARDS: Same exhibit? 
19 
MR. LU'FIIER: Yeah. 
20 
BY MR. LUTHER: 
21 
Q. Correct? 
22 
A. • Yes. 
23 
Q. Now, there was another incident that 
24 
happened April 2nd of'07, wasn't there? 
25 
A. Yes. 
34 (Pages 631 to 634) 
PROSE COURT REPORTING AGENCY, INC. 
'(561) 832-7506 
Electronically signed by cynthia hopkins (601-051.976.2934) 
Electronically signed by cynthia hopkins (601.051.976.2934) 
Electronically signed by cynthia hopkIns (601-051-976-2934) 
b5542fel-d299-4e4f-Sba6-85aad27f4405 
EFTA01108885

1 
2 
3 
4 
5 
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Page 635 
Q. And on that —
A. This is, this is the day that he found me at 
my new house. 
Q. That's April 2nd of'07 is when he found 
you in your new house? 
A. Yes. 
Q. And he forced himself in? 
A. Yes. 
1 
2 
3 
4 
5 
6 
7 
8 
Page 637 
A. Yes. 
Q.. And then he threw the knife? 
A. Yes. 
Q. Then he picked you up —
MR. LUIFIER: Or strike that. 
BY MR. LUTTIER: 
Q. And at that point you were seriously in 
fear for your son's and your life? 
9 
Q. And you were in your new house with your 
9 
A. Yes. 
10 
son, correct? 
10 
MR. LD7T1ER: Let me math that as 6, our 
11 
A. Yes. 
11 
next. And ask you if you can identify this 
12 
Q. Now, this incident scared you, didn't it? 
12 
document. 
13 
A. Yeah. 
13 
(Defendants Exhibit No. 6 was marked for 
14 
Q. I mean, he, he broke into your house. He 
14 
identification.) 
15 
took you. He took a knife. He put it in front of 
15 
THE WITNESS: I've had some crazy 
16 
your face and said I could kill you and your son, 
16 
boyfriends, but for three years everythings 
17 
didn't he? 
17 
been fine. 
18 
A. Yes. 
18 
BY MR. (MITER: 
19 
Q. And you were, when the police arrived, you 
19 
Q. Let me show you what has been marked as 
20 
were visibly shaking, you were crying and you were 
20 
Exhibit 6. Is that a copy of the Petition for 
21 
holding your son; isn't that right? 
21 
Injunction Against Domestic Violence that you filed? 
22 
A. I don't know if I was holding my son, but yes. 
22 
A. What about it? 
23 
Q. All right. And you, you swore out a 
23 
MR. EDWARDS: He was just showing it to 
24 
complaint to have him prosecuted for aggravated 
24 
you. 
25 
battery and false imprisonment, right? 
25 
THE WITNESS: Yes, I saw it before. 
Page 636 
Page 638 
1 
A. Yes. 
1 
BY MR. LIJMER: 
2 
Q. I mean, this guy scared you, didn't he? 
2 
Q. Is that the copy of the petition that you 
3 
A. Yeah. 
3 
filed. That is it has your signature on it? 
4 
Q. And you filed an injunction for domestic 
4 
A. Yep. 
5 
violence on that incident on April 17th of'07? 
5 
Q. And then in August of'07, you then had a 
6 
A. Yes. 
6 
domestic v' 
ion with your then new 
7 
Q. Did you say yes? 
7 
boyfriend, a 
did you not? 
8 
A. Yes. 
8 
A. Y 
iinall 
9 
Q. And there you said under oath, that he 
9 
Q. And 
had grabbed you by the arm 
10 
kicked your door in at 3:00 in the morning, rushed 
10 
and pulled you through the house; is that right? 
11 
in your son's room, grabbed him up and took him in 
11 
A. Yeah. 
12 
the bathroom; is that right? 
12 
Q. And then he picked you up and brought you 
13 
A. Yes. 
13 
upstairs and wouldn't let you come down; is that 
14 
Q. That scared you, didn't it? 
14 
correct? 
15 
A. Yes, it did. 
15 
A. Yes. 
16 
Q. And after you got up and he grabbed the 
16 
Q. He literally picked you up and took you up 
17 
knife, he then kept you from getting off your bed 
17 
the stairs? 
18 
and told you he was going to kill you, didn't he? 
18 
A. He made sure I got up the stairs, yeah. 
19 
A. Yeah. 
19 
Q. How did he do that? 
20 
Q. And then he said he was going to kill your 
20 
A. He like grabbed my waist and make sure I went 
21 
son, right? 
21 
upstairs. 
22 
A. Yes. 
22 
Q. And why was he taking you upstairs? 
23 
Q. And he told you he was going take your 
23 
A. Because he did not want me to be downstairs. 
24 
insides of your body and shove them down your 
24 
Q. Okay. And your son was present for this, 
25 
throat didn't he? 
25 
ri ltt? 
(561) 832-7500 
35 (Pages 635 to 638) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051.976-2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
b5542tef-d299-4e4f-9ba6-85aad2714405 
EFTA01108886

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Page 639 
A. He was sleeping. 
Q. Okay. And as a result of that incident, 
you were afraid, correct? 
A. Yes. 
Q. You had — 
A. Because I went through it before. 
Q. You what? 
A. Because I went through it before. 
Q. And you swore out a complaint for a 
battery against him, did you not? 
A. Yes. 
MR. LUTHER: I need to take a quick 
break. 
THE VIDEOGRAPHER: Going off the record at 
4:19 p.m. 
(A brief recess was held.) 
THE VIDEOGRAPHER: We're back on the 
record at 4.30 p.m. 
BY MR. LUTTIER: 
Q. Do you actually, yourself, call 
Mr. Epstein's home asking him if you could come 
work, did you not? 
MR. EDWARDS: Object to the form, 
predicate, time-frame. 
Page 641 
1 
A. No. 
2 
Q. Do you know if any of them have consulted 
3 
with any lawyers about that other than your lawyers? 
4 
A. No. What they want to sue me along with 
5 
Jeffrey? 
6 
Q. Have you ever discussed yourself with them 
7 
their feelings about you having taken them to see 
8 
Mr. Epstein? 
9 
A. Yeah. 
10 
Q. And what did they tell you? 
11 
A. Jane Doe is very sensitive towards it. She 
12 
didn't like it at all. She just was a poor little girl 
13 
that I guess was influenced by me to go to Jeffrey's 
14 
house. 
15 
Q. But I mean has she ever asked you why did 
16 
you do that knowing what you knew or anything like 
17 
that or said she holds you responsible? 
18 
A. Ina way. 'don't 'mow the exact words but 
19 
she's definitely came to me and said why would you even 
20 
do that, why would we go there? You lmow, it, it hurts 
21 
our self-esteem. 
22 
And in M.'s aspect she was extremely 
23 
scared to go the first time. And me being one of 
24 
her best friends at the time, she just finally wont 
25 
after I begged her many times when I couldn't fad 
Page 640 
1 
BY MR. WITTER: 
Q. During this period of time that you were 
3 
going to see Mr. Epstein. Sometimes you called and 
4 
asked his people at his house whether, you know, you 
could come work, did you not? 
6 
A. Yeah. Because he told me to call if I had a 
girl. SO, l would call and ask is he available. 
8 
Q. Now, I want to ask you a couple questions 
9 
about your two friends, Jane Doe and again 
M
.
 
10 
A. Excuse me. 
11 
Q. You took Jane Doe to Mr. Epstein, did you 
12 
not? 
13 
A. Yes, I did. 
14 
Q. How many times did you take her? 
15 
A. I don't know. 
16 
Q. Has Jane Doe or III. or anyone else that 
17 
you took to Mr. Epstein discussed with you or anyone 
18 
else that you know of the potential for them suing 
19 
you? 
20 
A. Who suing me? 
21. 
Q. Any girl that you took to Mr. Epstein. 
22 
A. No. 
• 
23 
Q. Do you know if any of them talked to their 
24 
lawyers about suing you as a result of you taking 
25 
them to see Mr. Epstein? 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 642 
any other girl. And no, they both didn't like it. 
Who would like it? 
Q. Did you have any friends better then M, 
You know, would you consider her, she was your best 
friend, or is your best friend? 
A. At that time, no. 
Q. Who is your best friend now? 
A. 
Q. .How about now? 
A. My son. 
Q. Okay. Other than your son, a friend not 
family. Is she, is she your best friend still? 
A. Jesus, myself, my son. Why are you looking at 
me crazy? 
Q. Is she your best friend was the question. 
A. I don't have a best friend. Actually, yes, l 
do. Faith Skyman. 
Q. Who? 
A. Faith. 
Q. Who is she? 
A. My son's God mother. 
Q. Is she another person that is suing Jeff 
Epstein? 
A. Nope. She was affiliated with 
who died. 
(561) 832-7500 
36 (Pages 639 to 642) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by cynthia hopkins (601461.976.2934) 
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Page 645 
Page 643 
1 
Q. What, Faith Skyman, S-k-y-m-a-n? 
2 
A. Yeah. 
3 
S 
How was she affiliated with 
5 
A. She was good friends with her and I met 
6 
through her. And I took 
7 
to Jeffrey Epstein's house. 
8 
Q. Where does Faith Skyman live? 
9 
A. Rhode Island. 
10 
Q. Do you have the phone number for this 
11 
babysitter you say you use? 
12 
A. Yes. 
13 
Q. Debra Carrot? 
14 
A. Yes. 
15 
Q. What's her number? 
16 
A. I don't know it off the top of my head. 
17 
Q. Is she listed in the phone book? 
18 
A. Probably. 
19 
Q. Is she — you say she lives in the 
20 
Acreage? 
21 
A. Yes. 
22 
Q. Is she married? 
23 
A. No. 
24 
Q. Have you ever been to her house? 
25 
A. Yeah. 
1 
times you actually went? 
2 
MR. EDWARDS: Form. 
3 
THE WITNESS: What does that mean? 
4 
MR. EDWARDS: Answer if you know what that 
5 
means. Do you have physical proof, videotape. 
6 
Answer his question if you know what the answer 
7 
is.. 
THE WITNESS: No. No one videotaped me 
9 
and no, we didn't keep a log, no. 
10 
BY MR.. LUTI1ER: 
11 
Q. There is no record that you could consult 
12 
that would say I know I went 21 times or exactly how 
13 
many times because you kept a record of it? 
14 
MR. EDWARDS: Fonn. 
15 
THE WITNESS: No. 
16 
MR. EDWARDS: This is outside of whatever 
17 
records are in your client's possession. 
18 
BY MR. LUTTIER: 
19 
Q. And since you and Jane Doe and 
are 
20 
all represented by the same lawyer, do you recognize 
21 
that there is an inherent conflict amon:tathree 
22 
of you in terms of any accusations that M. and 
23 
Jane Doe would have against you for taking them to 
24 
Mr. Epstein? 
25 
MR. EDWARDS: Object to the form. 
Page 644 
1. 
Q. Does she rent, does she own, do you know? 
2 
A. No. 
3 
Q. Live alone or with somebody else? 
4 
A. Her brother. 
5 
Q. Same last name --
6 
A. I don't know. 
7 
Q. — as her and her brother, last name is 
Carrot? 
9 
A. I don't know. 
10 
THE VIDEOGRAPHER: Your mic is on your 
11 
chair. 
12 
BY MR. WITTER: 
13 
Q. Now, you've told us when you believe you 
14 
first went to Jeffrey Epstein and when you went the 
15 
last time. If 1 -- and I may have asked you at the 
16 
last deposition: You have no physical proof of when 
17 
you actually went, right, the actual dates that you 
18 
went? 
19 
MR. EDWARDS: Object to the form. 
20 
MR. LUTTIER: That would be like a 
21 
calendar or notes, something like that. 
22 
MR. EDWARDS: Form. 
23 
THE WITNESS: Nope. 
24 
BY MR. LUTTIER: 
25 
Q. And you have no physical proof of how many 
(561) 832-7500 
PROSE 
Page 646 
THE WITNESS: I don't understand what the 
2 
hell — 
3 
BY MR. LUTTIER: 
4 
Q. There is a conflict of interest. 
5 
Mr. Edwards can't represent one, one client suing 
6 
another one of his clients; you recognize that, 
7 
don't you? 
8 
MR. EDWARDS: Form. 
9 
THE WITNESS: Okay. 
10 
BY MR. WITTER: 
11 
Q. Have you seen Jane Doe's deposition? 
12 
A. No. 
13 
Q. Have you been told anything about it? 
14 
A. No. 
15 
O. Have you been told anything about 
16
case? 
17 
A. No. 
18 
Q. Who is actually representing you now? Do 
19 
you know the name of the law firm that now 
20 
represents you? 
21 
A. Whatever this law firm's called. 
22 
Q. Is it — did you sign a new fee agreement 
23 
with the new law firm? 
24 
25 
A. Yes. 
......„amia
ll
ihasniw
o it's whatever firm
37 (Pages 643 to 646) 
COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by cynthia hopkins (601-051.076-2934) 
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Page 647 
1 
with? 
2 
A. Yes. 
3 
Q. And did you ever meet any of the people 
4 
from the Rothstein, Adler firm? 
5 
A. No. 
6 
Q. Did you meet any investigators from the 
7 
Rothstein, Adler firm? 
8 
A. No. 
9 
Q. Have you ever been interviewed by any of 
10 
the investigators from there? 
11 
A. No. 
12 
Q. Do you know a man by the name of Jay 
13 
Hawell? 
14 
A. No. 
15 
Q. Have you ever heard of his name? 
16 
A. Of Jay Hawell? 
17 
Q. Jay Hawell, 
18 
A. No. 
19 
Q. Do you have this babysitter's phone number 
20 
in your cellphone? 
21 
A. No. I don't keep it in my cellphone. 
22 
Q. You, you don't keep your babysitters 
23 
number in your cellphone? 
24 
A. No. 
25 
Q. And you don't have it memorized? 
Page 648 
1 
A. No. 
2 
Q. So, what do you have to do when you want 
3 
to call a babysitter? 
4 
A. It's at home. 
5 
Q. So, if you're out and about and you need 
6 
to call the babysitter and tell her you'll be — 
7 
A. I usually keep it in my purse. 
Q. — there late you don't have any way to do 
9 
that until you get home? 
10 
A. I usually keep it in my purse and I am not 
11 
late. 
12 
Q. Where do you keep it? Do you have a phone 
13 
book in your purse? 
14 
A. No. I have a piece of paper with her number. 
15 
Q. Okay. Do you have that with you here 
16 
today? 
17 
A. No. 
18 
Q. So, as you sit here today you do not have 
19 
on your person anywhere Ms. Carrot's phone number, 
20 
is that right? 
21 
A. I do not have her number with me, no. 
22 
Q. Do you know somebody by the name of Paul 
23 
Cassel (phonetic)? 
24 
A. No. What time is it? 
25 
Q. 4:41. 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19. 
20 
21 
22 
23 
24 
25 
Page 649 
A. Okay. I have to pick my son up by 6 so —
MR. EDWARDS: Well be done. 
BY MR. LUTTIER: 
Q. At the beginning of this deposition you 
asked a question about whether or not somebody else 
was going to be here I think on behalf of you. And 
you made some reference to somebody you had met with 
about this deposition. Do you recall making that 
statement, asking whether or not this other person 
was going to be here? 
A. Uh.huh, yes. 
Q. Who were you referring to? 
A. His name is — I don't know his name. 
Q. Is it a lawyer? 
A. He's an attorney. 
Q. Not a paralegal. A guy named Farmer, 
Mr. Farmer? 
A. Ideal know. 
Q. Have you met this other person? 
A. Yes. 
Q. Where did you meet this other person? 
A. At the law firm. 
Q. Mr. Edward's law firm? 
A. Yes. 
Q. Down in Fort Lauderdale? 
Page 650 
A. Yes. 
Q. So, you've been down to his new law firm? 
3 
A. Yes. 
4 
Q. Did you review anything in preparation for 
5 
today's deposition? 
6 
A. Yesterday I talked to my attorney. 
7 
Q. Did you review any documents? 
8 
A. I reviewed a document, yes. 
9 
Q. What document? 
10 
A. I don't know. I don't know what document, 
11. 
sir. Sorry. 
12 
Q. You say you reviewed a document or 
13 
documents? 
14 
A. I reviewed a document. 
15 
Q. One piece of paper? 
16 
A. A few, a few pieces of paper. 
17 
Q. Okay. What were they? What did they have 
18 
on them? 
19 
MR. EDWARDS: Objection as to this line of 
20 
questioning calls for attorney-client privilege 
21 
information. She's not going it answer it as 
22 
to exactly what we went over in preparation for 
23 
the deposition. 
24 
BY MR. LUTTIER: 
25 
O. Other than notes mated b 
our la 
er 
38 (Pages 647 to 650) 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. • 
(561) 832-7506' 
Electronically signed by cynthia hopkins (601-051.976.2934) 
Electronically signed by cynthia hopkins (601-051-976.2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
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EFTA01108889

Page 651 
which I don't want to know about, did you review any 
2 
other documents in preparation for your deposition? 
3 
A. No. I have to be out of here at 5:30. 
4 
Q. Are you aware of the fact that the U.S. 
5 
attorney has alleged that your, the firm that 
6 
represented you initially, the Rothstein, Adler 
7 
firm, they've, they've alleged that it was a 
3 
criminal enterprise? 
9 
A. I heard that they did some naughty acts, yeah. 
10 
MR. EDWARDS: Form. 
11 
BY MR. LUTHER: 
12 
Q. And that the head of their firm was 
13 
charged with criminal racketeering? 
14 
A. Yes. 
15 
Q. Did you ever hear any specifics about 
16 
that, why they were charged with those things? 
17 
A. Some guy took some money. I don't know. I 
18 
don't care. 
19 
Q. Did you hear where, where he was getting 
20 
the money from? 
21 
A. No. 
22 
Q. Did you ever hear anything about how your 
23 
case may have been involved in any of that? 
24 
A. No. It's irrelevant to me right now. 
25 
Q. Does that mean you have never heard 
Page 653 
1 
in the garbage. 
2 
Q. Well, at the time we took your deposition 
3 
in September, you told us under oath that it was at 
4 
your home. Did you do something with it since --
5 
A. No. 
6 
Q. — your deposition on September 24th? 
7 
A. No. 
8 
Q. Well, it just didn't disappear, did it? 
9 
MR. EDWARDS: Form. 
10 
THE WITNESS: No. Me you being sarcastic 
11 
with me? 
12 
BY MR. LUTHER: 
13 
Q. No. I mean you had to do something with 
14 
it, right? 
15 
MR. EDWARDS: Form. 
16 
THE WITNESS: I didn't touch it. I can't 
17 
find it. I don't know where it is. It's not 
18 
in the house, so, song. 
19 
BY MR. LUTHER: 
20 
Q. Well, where did you think it was when you 
21 
testified definitively that it was in your home? 
22 
A. I thought it was in a couple of my papers that 
23 
I have and it's not. I thought it was where my Social 
24 
Security card was. It's not them, sir. End of 
25 
discussion. 
Page 652 
1 
anything or you just disregarded what you heard? 
2 
A. I disregarded what I heard. 
3 
Q. So, what did you hear? 
4 
MR. EDWARDS: You're asking her though 
5 
what she heard outside of any conversation with 
6 
me obviously? 
7 
MR. LUTHER: Yeah, oh, yeah. I don't 
8 
want you to tell me, I don't want you to ever 
9 
tell me anything your lawyer told you. 
10 
THE WITNESS: Oh, no, I didn't hear 
11 
nothing. 
12 
BY MR. LUTTIER: 
13 
Q. Okay. Now, in your previous deposition 
14 
you indicated that you had a book. I think you said 
15 
it had a red — it was a red book. !don't remember 
16 
if the color was right and you said it had a Bible 
17 
verse on it. Do you remember that testimony? 
18 
A. Yes. 
19 
Q. And at that deposition you told us 
20 
definitively that you had that at your home? 
21 
A. Yes. 
22 
Q. Where is that book now? 
23 
A. I can't find it. It's nowhere to be found. 
24 
Q. Well, what did you do with it? 
25 
A. I don't know. I moved a lot so it's probably 
Page 654 
1 
Q. Do you know the names of any of your 
2 
clients that you had when you were working — other 
3 
than the ones you've aheady identified here, 
4 
clients you had when you were working for any of the 
5 
escort services? 
6 
A. No. Why would they want me to know their 
7 
names? I don't want to know their names either. 
8 
Q. I have no idea. 
9 
A. They have wives. 
10 
Q. All your clients have wives? 
11 
A. Probably. We don't — it's not about 
12 
relationships, man. It's about — 
13 
Q. When you were working for those --
14 
A. — money and out. 
15 
Q. — escort services, you were performing 
16 
sexual favors for their clients? 
17 
A. Okay. What about it? 
18 
MR. EDWARDS: Form 
19 
MR. LUTHER: Right? 
20 
MR. EDWARDS: Form. 
21 
BY MR. LUTHER: 
22 
Q. Did that give you any cause for any guilt 
23 
or feel bad about the fact that'you were out having 
24 
sex with married men? 
25 
A. Of course. 
• (561) 832-7500 
39 (Pages 651 to 654 
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Electronically signed by cynthla hopkins (901.051476.2934) 
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